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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 35
Authorizing Transactions Involving Credit Rating and Auditing Services
(a) Except as provided in paragraph (b) of this general license, all transactions ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of credit rating or auditing services to any person located in the Russian Federation that are prohibited by section 1(a)(ii) of Executive Order 14071 are authorized through 12:01 a.m. eastern daylight time, August 20, 2022.
(b) This general license does not authorize any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including transactions involving any person blocked pursuant to...
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1) Compare FAQ # 1038. Compare also Russia-related General License 13. As implicit from FAQ # 1034, "credit rating or auditing services" are within the scope of the EO 14071 service prohibition as “accounting” services.
2) Query: are credit rating services with respect to a Russian entity bond service supplied "to" the issuer, even if the services are provided at the best of, and for the benefit, of others?
3) See General Note on E.O. 14071-Based Prohibitions on the Exportation of Certain Services to Persons Located in Russia (System Ed. Note) for comments on the relevant prohibitions in general.